Document Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO No. 17 BK 383-LTS (Jointly Administered) THE COMMONWEALTH OF PUERTO RICO, et al. Debtors. 1 PUERTO RICO ELECTRIC POWER AUTHORITY, Debtor. No. 17 BK 4780-LTS Re: Dkt. Nos. 881, 88 Motion Relates Only to PREPA and Shall be Filed in Both the Lead Case No. 17 BK-383-LTS and in PREPA s Case No. 17 BK 4780-LTS JOINT MOTION FOR AN EXTENSION OF TIME IN CONNECTION WITH LORD ELECTRIC COMPANY OF PUERTO RICO, INC. S MOTION FOR ALLOWANCE OF ADMINISTRATIVE EXPENSE CLAIMS The Puerto Rico Fiscal Agency and Financial Advisory Authority ( AAFAF ), on behalf of the Puerto Rico Electric Power Authority ( PREPA ) pursuant to the authority granted to it under the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act -017, and Lord Electric Company of Puerto Rico, Inc. ( Movant ), by and through their undersigned counsel, 1 The Debtors in the jointly-administered cases, along with each Debtor s respective case number listed as a bankruptcy case number due to software limitations and the last four (4) digits of each Debtor s federal tax identification number, as applicable, are the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17 BK 383- LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation ( COFINA ) (Bankruptcy Case No. 17 BK 384-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Employees Retirement System of the Government of the Commonwealth of Puerto Rico ( ERS ) (Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (iv) Puerto Rico Highways and Transportation Authority ( HTA ) (Bankruptcy Case No. 17 BK 3567-LTS) (Last Four Digits of Federal Tax ID: 3808); and (v) Puerto Rico Electric Power Authority ( PREPA ) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 3747). ( case numbers are listed as Bankruptcy Case numbers due to software limitations).
Document Page of 7 respectfully submit this joint motion for entry of an order, substantially in the form attached hereto as Exhibit A, extending the deadlines in connection with the Motion for Allowance of Administrative Expense Claims [Case No. 17-04780, Dkt. No. 881] (the Motion for Administrative Expense Claims or Motion ) filed by Movant. In support of this motion, the parties respectfully state as follows: BACKGROUND On June, 018, the Movant filed the Motion for Administrative Expense Claims seeking the allowance of an alleged post-petition administrative expense claim in the amount of $1,091,860.96. Pursuant to this Court s order entered on June, 018, any opposition to the Motion for Administrative Expense Claims must be filed by July 6, 018, and any reply must be filed by July 13, 018 [Case No. 17-04780, Dkt. No. 88]. Counsel for AAFAF and Movant have had two conferences to discuss a mutually agreeable resolution of the Motion. Counsel for AAFAF, however, requires additional time to obtain and review information pertinent to the Motion. As a result, AAFAF requested, and Movant agreed, to extend the date by which AAFAF s response to the Motion is due. AAFAF submits that no party or creditor will be prejudiced by this extension. RELIEF REQUESTED In consideration of the foregoing, the parties have agreed to a seven (7) day extension of the applicable deadlines. The parties request entry of an order extending the deadlines as follows: Any opposition to the Motion for Administrative Expense Claims shall be filed by July 13, 018. The Financial Oversight and Management Board for Puerto Rico (the Oversight Board ), as the Debtors representative pursuant to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act ( ), 48 U.S.C. 101-41, has authorized AAFAF to file this motion on behalf of PREPA.
Document Page 3 of 7 Any reply in support of the Motion shall be filed by July 0, 018. WHEREFORE, the parties request the Court to enter an order, substantially in the form attached hereto as Exhibit A, (a) granting the motion and (b) granting such other relief as is just and proper. Dated: July 6, 018 San Juan, Puerto Rico Respectfully submitted, THE PUERTO RICO FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY, as Fiscal Agent for PREPA By its attorneys, /s/ Kevin D. Finger Kevin D. Finger (admitted pro hac vice) David D. Cleary (admitted pro hac vice) Greenberg Traurig, LLP 77 West Wacker Drive Suite 3100 Chicago, IL 60601 Phone: 31.456.8400 Fax: 31.456.8435 Email: fingerk@gtlaw.com clearyd@gtlaw.com Nathan A. Haynes (admitted pro hac vice) Greenberg Traurig, LLP 00 Park Avenue New York, NY 10166 Phone: 1.801.900 Fax: 1.801.6400 Email: haynesn@gtlaw.com LORD ELECTRIC COMPANY OF PUERTO RICO, INC. By its attorneys, /s/ Nanette Rickenbach Nanette Rickenbach USDC-PR No. 3008 Myrna Ruiz-Olmo USDC-PR No. 309 RICKENBACH OJEDA ATTORNEYS AT LAW PSC 400 Juan Calaf PMB 3 San Juan, PR 00918 Phone: (787) 73-8083 Fax: (787) 73-8085 Email: nrickenbach@rickenbachpr.com Joseph P. Davis (admitted pro hac vice) Greenberg Traurig, LLP One International Place, Suite 000 Boston, MA 0110 Phone: 617.310.6000 Fax: 617.310.6001 3
Document Page 4 of 7 Email: davisjo@gtlaw.com THE PUERTO RICO ELECTRIC POWER AUTHORITY By its attorneys, /s/ Arturo Díaz Angueria USDC No. 117907 /s/ Katiuska Bolaños-Lugo USDC No. No. 3181 CANCIO, NADAL, RIVERA & DÍAZ, P.S.C. PO Box 364966 San Juan, PR 00936-4966 Phone: (787) 767-965 Fax: (787) 764-4430 Email: adiaz@cnrd.com kbolanos@cnrd.com 4
Document Page 5 of 7 Exhibit A Proposed Order
Document Page 6 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO No. 17 BK 383-LTS (Jointly Administered) THE COMMONWEALTH OF PUERTO RICO, et al. Debtors. 1 PUERTO RICO ELECTRIC POWER AUTHORITY, Debtor. No. 17 BK 4780-LTS Re: Dkt. Nos. 881, 88 This Order Relates Only to PREPA and Shall be Filed in Both the Lead Case No. 17 BK-383-LTS and in PREPA s Case No. 17 BK 4780-LTS ORDER GRANTING JOINT MOTION FOR AN EXTENSION OF TIME IN CONNECTION WITH LORD ELECTRIC COMPANY OF PUERTO RICO, INC. S MOTION FOR ALLOWANCE OF ADMINISTRATIVE EXPENSE CLAIMS Upon the Joint Motion for an Extension of Time in Connection with Lord Electric Company of Puerto Rico, Inc. s Motion for Allowance of Administrative Expense Claims (the Motion ) 1 The Debtors in the jointly-administered cases, along with each Debtor s respective case number listed as a bankruptcy case number due to software limitations and the last four (4) digits of each Debtor s federal tax identification number, as applicable, are the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17 BK 383- LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation ( COFINA ) (Bankruptcy Case No. 17 BK 384-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Employees Retirement System of the Government of the Commonwealth of Puerto Rico ( ERS ) (Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (iv) Puerto Rico Highways and Transportation Authority ( HTA ) (Bankruptcy Case No. 17 BK 3567-LTS) (Last Four Digits of Federal Tax ID: 3808); and (v) Puerto Rico Electric Power Authority ( PREPA ) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 3747). ( case numbers are listed as Bankruptcy Case numbers due to software limitations). Capitalized terms used but not otherwise defined herein have the meanings given to them in the Motion.
Document Page 7 of 7 and the Court having found it has subject matter jurisdiction over this matter pursuant to section 306(a); and it appearing that venue is proper pursuant to section 307(a); and the Court having found that the relief requested in the Motion is in the best interests of the Debtors, their creditors, and other parties in interest, it is HEREBY ORDERED THAT: 1. The Motion is granted.. Any opposition to the Motion for Administrative Expense Claims shall be due on July 13, 018. 3. Any reply shall be due on July 0, 018. 4. This Court retains exclusive jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order. 5. This Order resolves docket entry no.. SO ORDERED. Dated:, 018 San Juan, Puerto Rico LAURA TAYLOR SWAIN UNITED STATES DISTRICT JUDGE